EMI & PI license: what is the difference?

November 9, 2022
EMI & PI license: what is the difference?

As experienced lawyers, we know what problems our customers may face while applying for an EMI license in Lithuania and a PI license in Lithuania. Lithuanian jurisdiction is fairly considered to be the fastest-growing Fintech sector in the EU, and the 2nd-fastest growing in Europe. To date, there are over 200 EMIs and PIs with an international outreach domiciled in Lithuania. So what is the difference between EMI and a PI license? Let’s figure it out.

Under the Lithuanian law (Law on Financial Institutions IX-1068 as of 24th November 2015), the operations of payment service providers (PSPs) and electronic money issuers (EMIs) are overseen by the Central National Bank (CNB). The provisions of Lithuanian law stipulate the below-listed authorizations for EMIs and PIs.

General comparison of EMI and PI

Services of electronic money institution (EMI) in Lithuania:

  • Issuance and redemption of electronic money;
  • Receiving and holding clients’ funds without instructions for payment initiation;
  • Payment services;
  • Currency exchange;
  • Lending services (for this type of activity additional registration is mandatory).

Services of payment institution (PI) in Lithuania:

  • Payment services;
  • Currency exchange;
  • Lending services (for this type of activity additional registration is mandatory).

Core obligations to obtain the license of EMI or PI in Lithuania:

Minimum capital obligation:

  • EMI: at least 350 000 Euros;
  • PI: From 20,000 euros to 125,000 euros, subject to the services offered;

Managers and mandatory positions

  • EMI and PI: The CEO and management must have at least three members. CEO and directors must possess an excellent reputation and the appropriate qualification and expertise needed to properly carry out their duties.

Evaluation of the shareholders in the applicant’s business

  • EMI and PI: The Bank of Lithuania evaluates the ultimate beneficiary of the applicant grounded on submitted data and filled-in questionnaires.

License fee

  • EMI: 1,463 euros;
  • PI: 868 euros;

Time considerations

  • EMI and PI: three month-term which can be prolonged.

ELI Lithuania provides legal support to our clients during licensing of EMI and PI, drawing up the package of necessary licensing documentation, assisting with company formation, representing our clients in the supervising authority, and providing advisory services. After the regulator issues an EMI or PI license, we also can provide compliance, regulative reporting, and legal services.

If you want to obtain a license for electronic money in Lithuania or a payment institution license in Lithuania, please contact us for further information.

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  • To incorporate a company in any jurisdiction, please contact our specialist, we’ll send you all relevant information.

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